PUBLIC CONSULTATION AND DISCLOSURE PLAN AZERI, CHIRAG & GUNASHLI (ACG) PHASE 3 PROJECT REV 0

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1 AZERI, CHIRAG & GUNASHLI (ACG) PHASE 3 PROJECT REV 0 July 2003

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3 TABLE OF CONTENTS 1. INTRODUCTION PROJECT DESCRIPTION ACG PHASE ACG Contract Area and Field Development The ACG Phase 3 Project Description REQUIREMENTS FOR CONSULTATION & DISCLOSURE Introduction National Requirements for Consultation & Disclosure The EIA Handbook INVENTORY OF STAKEHOLDERS AIOC Stakeholder Identification and Analysis Process ACG Phase 3 Project Stakeholder Inventory Scoping Consultation REVIEW OF PREVIOUS CONSULTATION UNDERTAKEN IN RELATION TO THE PROJECT Introduction Key Issues Identifed from the Review Integration of Project and Operations Activities & Initiatives Resolution of Prior ACG Project Commitments Extension of the Geographical Scope of the Community-based Consultation Stakeholder Fatigue PROGRAMME AND SCHEDULE OF CONSULTATION & DISCLOSURE ACTIVITIES IN RELATION TO ESIA STAGES AND PROJECT IMPLEMENTATION Summary of Types of Methods to be Used Schedule of Consultation Activities & Plan for Integration with ESIA & Project Activities Allocated Budget for the ACG Phase 3 ESIA Consultation Management of Media Publicity Management and Staff Resources Allocated to the Plan Tasks EVALUATION CRITERIA FOR ASSESSING PCDP EFFECTIVENESS...23

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5 1. INTRODUCTION This document outlines the public consultation and disclosure plan (PCDP) for the ACG Phase 3 project. It has been developed in the context of the ongoing consultation programme for the ACG full field development that commenced prior to the Phase 3 ESIA process and will continue throughout the life of the project. The PCDP defines a technically and culturally appropriate approach to consultation and disclosure for the project. It demonstrates the links between consultation and the project decision-making process and makes the most appropriate use of existing initiatives and communication mechanisms employed by AIOC. The scope of this plan reflects local circumstances, in particular, the previous experience of the stakeholders with respect to oil and gas exploration and production (E&P) activities related to the ACG development and with other international E&P projects. The goals of the PCDP are to ensure that: the project team clearly understands what consultation is and why this is important; the scope of the consultation programme and the roles and responsibilities of project personnel are clearly defined and understood; and stakeholders fully understand the decision-making process and the means by which they can be involved. To this effect the plan sets out to further ensure that: adequate and timely information is provided to project-affected stakeholders; these stakeholders are given sufficient opportunity to voice their opinions and concerns; and these concerns influence project decisions. A number of activities and outputs, against specific timescales and assigned responsibilities, required in order to achieve these goals, are presented in the PCDP. These will form the basis for evaluating the performance and effectiveness of this PCDP. This document is a working document that will need to be updated routinely as information is received and the positions and interests of stakeholders are clarified. This PCDP is linked to key internal AIOC information sources that are of material relevance. These include inter alia: The ACG Phase 3 FEED Team Option Analysis Reports and ENVIID Registers & associated Action Tracking documentation; The Government and Public Relations (GPR) Stakeholder Analysis Database; The GPR Database of articles published in the Media; The GPR Database of Holding Statements; The ESIA Team Database of consultation records (including records for Phases 1, 2 and 3); The Sangachal Terminal Expansion Project (STEP) Database of community based consultation records for Sangachal Village and Umid Settlement; 1

6 Commitments Register and Monitoring Register for the ACG Project (based on Phases 1 and 2 ESIAs); and Community Relations Plan for the Phase 1 ACG project. Together with the activities and outputs proposed in this PCDP these information sources provide an effective basis for a transparent issue identification and management process that is essential for the implementation of the Public Consultation and Disclosure Process. 2

7 2. PROJECT DESCRIPTION ACG PHASE ACG Contract Area and Field Development The Azeri, Chirag and Deep Water Gunashli (ACG) Contract Area has estimated oil reserves in excess of 5.2 billion barrels. It lies in the Azerbaijan sector of the Caspian Sea, approximately 120 km south east of Baku. The Contract Area covers an area of 432 square kilometers in water depths ranging from 100 m to 400 m (Figure 1). Figure 1 The Location of the ACG Contract Area A Production Sharing Agreement (PSA) was signed in 1994 between the State Oil Company of the Azerbaijan Republic (SOCAR) and the Azerbaijan International Operating Company (AIOC), a consortium of foreign oil companies. The Agreement grants the consortium rights to develop and manage the hydrocarbon reserves found in the ACG field. In 1999 BP was appointed operator of AIOC. AIOC is in the process of developing the ACG oil field. Work first began in 1995, culminating in oil production from the Chirag field in 1997 (the Early Oil Project). AIOC is continuing with the development of the Central area of the Azeri field (ACG Phase 1 Project with first oil production is scheduled for late 2004), and the West and East areas of the Azeri field (ACG Phase 2 Project, with first oil production planned for 2006). Both phases of development have been subject to Environmental and Social Impact Assessments (ESIAs) and Environmental Statements have been disclosed locally and internationally. The ACG Phase 1 and the Phase 2 ESIAs are now approved by the Azerbaijan Ministry of Ecology and Natural Resources (MENR). The ACG Phase 3 project completes ACG full field development. It is expected that Phase 3, together with the Early Oil Project and Phases 1 & 2, will achieve plateau production of around 1MMbd by

8 ACG Phase 3 will develop the Deep Water Gunashli field, and will also carry some preinvestment should the option be exercised at a later date to place a development in the West Chirag Field. ACG aims to achieve first oil production by early 2008 (Figure 2) Phase3 8 Early Oil Deep Water Chirag Gunashli /West Chirag 2006 Phase2 West Azeri 2004 Phase1 Central Azeri 2007 Phase 2 East Azeri Figure 2 Development of Azeri, Chirag and Gunashli Oil Field 2.2 The ACG Phase 3 Project Description The Base Case offshore field development concept for the Phase 3 project consists, of a Production, Drilling, Utilities & Quarters (PDUQ) platform, located in Deep Water Gunashli, with a bridge-linked gas export Compression and Water-injection Platform (C&WP). The facilities will be broadly similar to those installed for Phase 1, however, work is currently ongoing to evaluate opportunities to reconfigure and optimize topside design for both platforms. The oil and gas is expected to be exported to shore via new infield flow-lines and the existing pipelines laid as part of the Early Oil Project and Phases 1 and 2 (Figure 3). Sangachal Terminal 2008 Phase 3 DWG 1997 Early Oil Chirag 2006 Phase 2 West Azeri 2005 Phase 1 Central Azeri 2007 Phase 2 East Azeri 2x800mbbl storage tanks?? 24 oil pipeline 2 x 30 oil pipelines +? 28 gas pipeline Figure 3 The Azeri, Chirag and Deep Water Gunashli Full Field Development as conceived at the present time 4

9 Table 1 Onshore the ACG Phase 3 project will include expansion of the existing Sangachal Terminal (Figure 4). The expansion will involve the installation of two additional trains of oil, gas and water separation and stabilization plant, together with associated power and utilities systems and the provision of oil storage and cross connections into the produced water system. Export routes for the oil include the Western Route Pipeline, Northern Route Pipeline, and Baku-Tblisi-Ceyhan Pipeline. A programme of drilling using the mobile drilling rig, the Dada Gorgud, is planned to commence in 2006 and last around a year. Construction of the platforms and terminal expansion will likely begin in If the platforms are constructed within Azerbaijan, some upgrade to existing yards may be required before construction can commence. First oil production is planned for late It is currently anticipated that platform wells will be drilled from 2008 onwards. These will comprise production, and water injection wells and one further cuttings injection well. The Production Sharing Agreement allows AIOC the right to produce oil until 2024, after which time the facilities will be handed to the State Oil Company of the Azerbaijan Republic. The Phase 3 Project has developed a milestone schedule (summarized in Table 1 below) to meet its target first oil date. ACG Phase 3 Project Milestones Description Front End Engineering Design (FEED) start August 2003 Project sanction July 2004 Start fabrication 4Q 2004 Commence pre-drilling wells 2Q 2006 First platform topsides installed 2Q 2007 Second platform topsides installed 4Q 2007 First Production (Oil at Wellhead) 4Q 2007 In order to achieve this schedule AIOC will submit an Environmental Statement for the ACG Phase 3 Project to the Ministry of Ecology and Natural Resources (MENR) in mid Allowing for a 60-day Public Disclosure period and incorporation of MENR and other stakeholder comments, a decision on approval is anticipated in 3Q

10 T ACG Phase 3 ACG and SD Flare Area ACG Phase 2 Azeri ACG Phase 1 Azeri BTC Phase 3 Azeri Azeri 1300 m Shah Deniz SD Power Island EOP Terminal 2080 m Figure 4 The Various Development Phases of the Sangachal Terminal 6

11 3. REQUIREMENTS FOR CONSULTATION & DISCLOSURE 3.1 Introduction Communication with organisations, groups and individuals (known collectively as the stakeholders) is an important part of the way that the Azerbaijan International Operating Company (AIOC) conducts its business. Communication with the project stakeholders is an essential component of any environmental and socio-economic assessment (ESIA) process. Through its communication programme for the ACG development AIOC seeks the views of interested or affected stakeholders through engaging them in two-way dialogue. AIOC can then apply the local knowledge learned through this feed back process to the evaluation of alternatives to proposed activities and resolution of and /or avoidance of potential conflicts. Such an approach can assist in developing a cooperative relationship between AIOC and its stakeholders, facilitate stakeholder ownership and acceptability of AIOC s proposals and limit unrealistic expectations. AIOC is committed to active and ongoing communication with all stakeholders regarding the ongoing ACG Full Field Development (FFD) activities and the proposed ACG Phase 3 project activities AIOC is committed to maintaining the same standard of consultation across the ACG FFD development. As such the consultation programme for Phase 3 will be conducted with specific reference to the relevant international finance organization guidelines and standards (i.e. IFC and EBRD) that were applied during earlier phases. In addition the requirements of relevant international conventions (eg. the Espoo and Aarhus Conventions), European Community Directives and national regulations will be applied. The requirements of the relevant international finance organizations, the European Directives and International Conventions of specific relevance for consultation are outlined in the Phase 1 and Phase 2 PCDPs, and have not been reproduced here. 3.2 National Requirements for Consultation & Disclosure The EIA Handbook National requirements for public participation in ESIA are outlined in the Handbook for the Environmental Impact Assessment Process in Azerbaijan 1996, which was developed with the support of the United Nations Development Programme. The EIA Handbook includes definition of the legal requirements for public participation, outlines the opportunities for public to be involved in the process of decision-making, and recommends public information mechanisms. The main regulating environmental body is the Ministry of Environment and Natural Resources (MENR), recently formed from the merger of four state organizations comprising the State Committee for Ecology, State Committee for Hydrometeorology, State Forestry Committee and the Sate Committee for Geology. The MENR is responsible for setting up an expert panel (Environmental Review Expert Group) to review and approve an EIA. 7

12 The EIA Handbook defines public as anyone who is in any way affected by the proposal or has a genuine interest in it. This includes local residents living in the vicinity of the project area, individuals who have their interest in the project, community groups, professional organizations, and industries and enterprises. In some cases, government agencies that participate in the EIA process may also be considered part of the general public. The most important requirement that ensures effective public participation is for AIOC to inform the public about the project at an as early stage of the project as possible. An effective feedback system is required to ensure that the public has not only been consulted but that their opinion will be acknowledged and accounted for. It is the responsibility of the Environmental Review Expert Group to collect and document feedback and provide copies to AIOC. In practice BP/AIOC have taken on this process of consultation and feedback. The EIA Handbook recommends effective ways for the public to be involved in the environmental decision-making. The most effective means of expressing concern, support, or general opinion about the project is by means of written submission. Other recommended means of public participation include discussion forums about particular technical aspects of the project, live television debates and radio discussions. It is pointed out in the EIA Handbook that the most powerful information document is a written submission. In the case of an EIA there are two documents which provide public information. The first document is the Environmental Statement prepared by AIOC, the second document is that produced by the Environmental Review Expert Group. Both documents must be made available to the public. In addition to these project specific documents, the public is also encouraged to draw general environmental information from the State of the Environment Report for Azerbaijan, and other various sources including environmental atlases and the media. Finally, the EIA Handbook stresses the importance of enabling the public to receive the information that they believe they need. 8

13 4. INVENTORY OF STAKEHOLDERS 4.1 AIOC Stakeholder Identification and Analysis Process AIOC already has an established programme of stakeholder consultation in Azerbaijan. The goal of the ACG Phase 3 Project is therefore to build on the work already undertaken. At the time of writing, the AIOC Government and Public Relations (GPR) department, in collaboration with the AIOC HSE department, are progressing a stakeholder identification and analysis process. The key purpose of this process is to bring together the knowledge held by individuals throughout AIOC on both the primary stakeholders (i.e. those directly affected by the project) and the secondary stakeholders (i.e. those not directly affected, but whom may have an influence, interest or expertise to offer). The objective is to classify the stakeholders with respect to their attitude, importance, influence and key area of interest, in order to assist in the process of prioritizing consultation; and to identify both existing and potential opportunities for partnerships and collaboration. It is anticipated that the output from this process will also provide an indication of whether or not and by what means AIOC has previously liaised with specific individuals, organizations and focus groups. The inventory of stakeholders will include those at the local, national and international levels. This GPR led initiative will consolidate the knowledge and lessons learned about AIOC s stakeholders from previous phases of the ACG project, in addition to drawing on external resources such as local NGO directories. The output from this process will form the key linked resource to this section of the PCDP, when available. A second key linked resource to this section of the PCDP is the records on communitybased consultation at the Sangachal Village and Umid Settlement held and managed by the Sangachal Terminal Expansion Project (STEP) Community Liaison Officer. 4.2 ACG Phase 3 Project Stakeholder Inventory Whilst the GPR stakeholder analysis is ongoing, the Phase 3 stakeholder inventory has been based on the inventory built for Phase 1 & 2 (see below), and will be used to develop a database of stakeholders and relevant profile information for each stakeholder Scoping Consultation For the purpose of identifying the key stakeholder groups to be consulted, for the scoping phase of the ACG Phase 3 project ESIA, particular reference was made to the ACG Phase 1 and Phase 2 project consultation summary documents and stakeholder lists. Further clarification was sought through interviews with key AIOC personnel both within the GPR department and within the HSE department, who had previously been involved in the ACG project ESIA consultation process. Additional advice was also sought from the Sangachal Terminal Expansion Project (STEP) HSE team on the appropriate community representatives to consult. Notably, the Scoping consultations focused on community representatives within Umid Settlement and Sangachal Village. However, the potential need to widen the geographical scope of the community-based consultation programme was identified, which will necessarily result in the identification of new project stakeholders (see Section below). Overall, greater emphasis was given to the community based consultation within the scoping 9

14 consultation programme for the ACG Phase 3 project compared to the programmes for the ACG Phase 1 and 2 projects. This was facilitated through the collaboration with the STEP HSE team that enabled the integration of the consultation activities into their ongoing community liaison initiative. The inventory of stakeholders consulted during the ACG Phase 3 ESIA scoping phase, together with the issues raised and method of consultation, will be provided in the ACG Phase 3 Scoping Report. 10

15 5. REVIEW OF PREVIOUS CONSULTATION UNDERTAKEN IN RELATION TO THE PROJECT 5.1 Introduction To date consultation programmes have already been undertaken for previous phases of the ACG Field Development programme including the Early Civils Engingering Work Programme, Early Template Well ESIA, Regional Seismic ESIA, Early Oil and ACG Phases 1 & 2 ESIAs. A detailed review is presented in the Phase 1 PCDP and has not been reproduced here. The lessons learned from these consultations, from a review of the Phase 2 consultation programme, and consultation initiatives since the submission of the Phase 2 ESIA, have been drawn on in the development of the consultation programme for ACG Phase 3 ESIA process. 5.2 Key Issues Identifed from the Review The key issues for the ACG Phase 3 project ESIA consultation programme, identified as a consequence of this review, are presented below Integration of Project and Operations Activities & Initiatives For the ACG Phase 3 project the opportunities for undertaking community based consultations have increased significantly compared to previous phases of the project. This is as a consequence of the establishment of a community liaison programme and social investment/community development programmes for the communities in the immediate vicinity of the Sangachal Terminal site. This has resulted in regular interaction between the ACG project personnel, especially the terminal staff, and the local communites. Further, since there are ongoing project and operational activities running concurrently with the ACG Phase 3 ESIA process, it will be essential to integrate and co-ordinate the ACG Phase 3 ESIA consultation activities and initiatives with those of the other phases of the ACG project. This requirement is further supported through preliminary discussions with the Terminal Manager and the Community Liaison Officer during which they indicated that many local individuals do not distinguish project 'phases' and see only one big project. Thus, given the continuing framework of consultation (on many issues) between the terminal management and local communities it has been decided that the ACG Phase 3 ESIA consultations will be more effective if they were to occur within this framework, with the terminal team assisting with the consultations. This approach should avoid any misunderstandings arising from external unknown individuals, who lack knowledge of the issues and their context, seeking information from consultees alone Resolution of Prior ACG Project Commitments The ACG Phase 3 project is the final phase of the Full Field Development, and as such stakeholders will be looking for this phase to provide a status on the resolution of commitments made during previous phases of the project Extension of the Geographical Scope of the Community-based 11

16 Consultation AZERI, CHIRAG & GUNASHLI FULL FIELD DEVELOPMENT PHASE 3 A need has been identified to extend the geographical scope of the consultation programme beyond the Umid Settlement, Sangachal Village, and Sahil Town, to the wider Garadag region. It is anticipated that this wider geographical area will encompass a higher proportion of the employment and supporting services catchment for the project activities. The potential need to extend the geographical scope of the consultation programme has also been identified for a number of specific options, currently under consideration for the ACG Phase 3 Project, if they were to be selected. In particular, consultations could be required in the vicinity of the ATA Yard if this was selected for undertaking construction / fabrication activities for the ACG Phase 3 project. Further, if the Lokbatan site was selected for disposal of produced water there could be a need to communicate with the stakeholders on this issue. The social baseline assessment will determine the need for any specific consultations. As project decisions had not been made at the time of undertaking the ACG Phase 3 Project scoping consultations as to whether or not the ATA Yard and Lokbatan site would be used a decision was therefore made to postpone associated consultations until such a time as the project position was clarified. However, baseline socio-economic data has recently been collated as part of the ACG Phase 2 project activities that will provide useful input into the identification and analysis of the new stakeholders in the vicinity of the ATA Yard Stakeholder Fatigue Stakeholder fatigue was identified as a potential issue for the ACG Phase 3 project as a consequence of the extensive programme of consultation undertaken for previous phases of the project. To try to overcome this possible 'barrier' to effective consultations, the consultations with a number of stakeholders will focus on a discussion of current socio-economic mitigation measures and community development/social investment programmes. This allows stakeholders to raise concerns and provide feedback and thus help determine their effectiveness and the need for any further intervention 1. 1 This was the approach adopted for the ACG Phase 3 Scoping Consultations where it proved effective, with, in particular, useful comment obtained on current social programmes being run by the STEP (please refer to the ACG Phase 3 Scoping Report). 12

17 6. PROGRAMME AND SCHEDULE OF CONSULTATION & DISCLOSURE ACTIVITIES IN RELATION TO ESIA STAGES AND PROJECT IMPLEMENTATION 6.1 Summary of Types of Methods to be Used A range of consultation methods will be used depending on the aim of the consultation and the type of stakeholders. Below, the methods are described according to the activities involved in the ESIA. Scoping Consultations There are two main types of scoping consultations. First, there will be scoping workshops with three main groups: The Research and Monitoring Group (a body established under the ACG PSA to advise on environmental issues); The Scientific Community; and Non-Governmental Organizations (NGOs). These groups have been consulted by AIOC for the ESIAs for earlier project phases. They are familiar with the overall project concept and its implementation in three separate, but linked phases. The members of these stakeholder categories are all based in Baku or its immediate environs. Also, they are well educated, accustomed to ESIAs and the scoping process, and understand their links to project design and implementation. Consequently, following previous precedent, a workshop approach is proposed. The workshops will be of 1-day duration. They will share a common agenda (see table below). The day begins with presentations on the Phase 3 ESIA process and an account of the key characteristics of the phase 3 development. This is followed by a presentation of environmental monitoring undertaken for earlier ACG Phases and the results to date. All presentations will be supported by a PowerPoint presentation (with hard copies distributed in advance in Azeri or Russian). Following each presentation there will be a question/answer session. After lunch the participants will be divided into working groups to identify key impacts and other concerns for Phase 3 (for academics and NGOs only). The proceedings of the entire day will be recorded and a summary report of the proceedings prepared and used as input to the Scoping Report. The meetings will be conducted in Azeri and Russian with the aid of translators for the benefit of English speaking attendees. Feedback forms will be distributed to provide individuals who had not had the opportunity to raise an issue or who required further clarification to communicate this. Notably, for the meeting for the NGOs a presentation of the ACG social investment / community development programmes will be included as an additional item to the agenda (see Box 1 below). This has been added on the advice of AIOC personnel that a number of the NGOs will have a primarily social rather than environmental focus and would therefore be looking to be provided with information on these programmes. 13

18 Box 1: Agenda for Stakeholder Consultation Workshops - Baku 1. Goals and objectives for the workshop regarding input to scoping process 2. ACG development Phase 3 ESIA process 3. ACG development Phase 3 Project within the context of full field development of Azeri, Chirag fields and deepwater portion of Gunashli Field 4. ACG development Social Investment / Community Development Programmes (NGOs only) 5. General review of key aspects 6. Current and planned initiatives on environmental monitoring 7. Working groups to identify issues of concern for investigation in the ESIA 8. Presentations by working groups to plenary session During previous phases of the ACG project an NGO (based in Baku) that is concerned with protecting the rights of oil workers was identified. It is considered important to consult with a representative of this NGO, especially with regard to employment related and local oil and gas business development related social and economic impacts and issues of concern. This consultation will be based on an interview using a semistructured questionnaire to guide and record the discussion. Second, scoping consultations will be held with key individuals and focus groups from the local communities living in the vicinity of the Sangachal terminal. In previous phases of the ACG project a public meeting approach had been adopted. Whilst this resulted in a significant attendance it is considered that this type of consultation makes it difficult for some groups such as women, teenagers and elders to express their personal views. In particular there is the risk that the views expressed at the meetings will be dominated by one specific group with other groups feeling uncomfortable or unable to express their personal views in the presence of this dominant group. The proposed approach provides for a greater emphasis on a focus group, rather than public meeting approach to community-based consultation. Based on discussions with the STEP team members it is intended that the stakeholders involved in these consultations will comprise those stakeholders and stakeholder groups listed in Box 2 below. Box 2: Local Community Stakeholders 1. Garadagh Executive Power (Lokbatan [headquarters for Garadagh District] and representatives of the Executive Power Committee in Sangachal and Umid) 2. Manager of the Information Centres 3. Councils of Elders (Aksakkals) of Sangachal and Umid 4. Community Development Councils in Sangachal and Umid 5. School Directors (one each from Sangachal and Umid) 6. Women Focus Group 7. Young people Focus Group (ages approximately from 13-19) 14

19 The methods to be used will vary. All interviews will be undertaken using a semistructured questionnaire. The number and type of questions will depend on the stakeholder. Community members (as opposed to those in 'official' positions) will be consulted in an informal 'discussion' style mode focused around a few open questions. Since construction began on the terminal site there have been many interactions between AIOC (particularly terminal management) and local community representatives/individuals. Additionally, AIOC has been implementing a Social Investment / Community Development Programme in the local communities. This Programme is funding a number of projects to assist the local communities. One of these projects is being managed by the international NGO, World Vision. It is considered that the AIOC Sangachal Terminal Community Liaison Officer and / or World Vision should assist with these consultations as discussed in There are some key project decisions still to be made as discussed in for which further scoping consultation could still be required. For example, the ATA yard may be selected for part of the construction / fabrication activities and a site in Lokbatan may be selected for disposal of produced water. It is considered inappropriate to undertake consultations in the vicinity of these localities until AIOC has made these key decisions. Such consultations may create expectations or enhance fears needlessly. However, once the decisions are made consultations can still occur and be incorporated into the ESIA process for Phase 3. Similar methods to those identified for scoping consultations in the communities in the vicinity of the Sangachal terminal will be used for these scoping consultations. The ATA yard is undergoing an upgrade, at present, and a baseline social survey has been carried out for the site that has identified some key stakeholders in the area. The results of this work will be used as a key input to any scoping consultations that may be undertaken as part of the Phase 3 ESIA process. The scoping report will be submitted to the MENR, placed on the BP Projects website, and copies placed in the Information Centres within the local communities. ESIA Preparation It is anticipated that the key element of the consultation process during ESIA preparation will be communication of the progress of outstanding commitments from earlier phases of the ACG project and communication of the decision making process for the ACG Phase 3 facilities design. This will require an underlying robust issues management system that allows for the maintenance of a transparent and auditable trail. Typically, the methods adopted and results of the project decision-making process have been presented within the Environmental Statement and the process disclosed in this way to the interested stakeholders. However, during the ACG Phase 3 Scoping consultations the NGOs, in particular, expressed a strong desire to be involved earlier in the process whilst the decisions were still being made. It would not be practical to involve only certain stakeholder groups in consultations during the ESIA preparation phase of the ESIA process, as this would create a bias in the feedback. Therefore any programme for consultation during this phase would need to be designed to facilitate consultation with all stakeholder groups. It is proposed that written bulletins (holding statements) be prepared on key environmental and social issues of concern to stakeholders, detailing the suggested approach, design, and control measures being considered by the project. These will be 2 At the time of writing the scoping consultations have been completed and the results are contained in the Scoping Report for the ACG Phase 3 ESIA. 15

20 distributed to key project personnel and representatives of organizations or groups who are then charged with the responsibility for further disseminating the information and collating feedback. For example within the local communities either the Community Liaison officer or the head of the local Executive Power or the Community Development Committees could be charged with the responsibility for the Sangachal Village and Umid Settlement. Representatives of the academics and the R&MG could be nominated for these groups, and an organization that provides capacity building support to local NGOs could be used to co-ordinate the communication and collation of feedback from the NGOs. Draft ESIA report Once the environmental statement is completed it will be available for comment. It will be issued in Azeri, Russian and English and placed on the BP project website 3. Copies, containing an Executive Summary, will be placed in locations with easy public access such as schools, libraries, Community Information Centres, the Human Development Centre, BP Villa Petrolea reception, Executive Power offices, and the new Environmental Information Centre within the Ministry of Ecology and Natural Resources. Notification will be given through newspaper advertisements and posters, and written comments requested within the formal 60 day consultation period. A public meeting will be held in Baku. This public meeting will be announced in the media and information will be posted in prominent public places. The meeting will begin with a presentation outlining the project, the ESIA process followed, and the key findings/recommendations of the ESIA Report. This will be followed by a question and answer session. The public meeting will be held in the evening rather than during the day to allow those that are working to attend. The public meeting will be supplemented by a series of community-based focus group round table discussions. The groups involved will include those consulted during the scoping phase and any additional focus groups identified during the course of the EISA preparation process. Finally an open day is proposed, to be held at a venue or venues yet to be determined, at which information will be provided on the project, Phase 3 project personnel would be available to answer questions and members of the public will be able to voice opinions and concerns with regards to the project. All questions asked and issues raised will be documented. It is suggested that the open day be run as a table session, with each table designated for discussion of a different key issue. The themes will be determined nearer the time when the ESIA team is clear on the areas they feel should be the focus of consultation with respect to the community interests. It is recommended that consideration be given to ensuring that the form and content of the day be conducive for all members of the community to attend (e.g women members of the project team will be present in order to encourage women to attend). Interpreters will also be available

21 All comments will be collated and analyzed and entered into a reporting template format that provides for AIOC to summarize its response to comments. It is proposed that a similar format is used to that used in the Supplementary Lenders Information Package prepared for Phase 1 (available on the BP projects website 4 ). Once completed this template can then be incorporated into the final ESIA report. Final ESIA Report Copies, in English, Russian and Azeri, of the ESIA Report will be placed in the public domain and announced? as per the draft ESIA Report. Post-ESIA Project Consultations Considerable attention has been given in the PCDPs of the earlier phases to the type and nature of post-esia consultations (especially the Phase 1 PCDP). Since terminal construction began a community relations programme has been initiated and appears to be working well. It is realized that there is an existing framework and that it should only be altered for a very good reason. The Complaints Procedure detailed in the Phase 1 PCDP will be adopted also for Phase 3. Phase 3 is about to begin and will be followed directly by an operational period of many years. It is therefore considered appropriate at this time to consider how community consultations should be structured to best meet the needs of the project operators and the local communities. At present, the programme of community consultations being led by the STEP team is strongly linked to the Social Investment /Community Development programme and it would appear that currently the consultation effort is focused on these programme issues, and thus on the Sangachal Village and Umid Settlement Communities. The construction Environmental Management System is now better developed and understood, allowing a proactive approach to the management of issues such as noise, traffic movement, and other potential community nuisances. It is expected that project environmental and social aspects (as identified within the Environmental Management System aspects register), and their associated control and mitigation measures, will be subject to regular review and analysis using performance data. Analysis of the data collated through the Complaints Procedure can form part of this performance data, and feedback can be provided to the communities on performance (eg. results of noise monitoring). Consultation Under the Espoo Convention Azerbaijan is a signatory to the Convention on Environmental Impact Assessment in a Transboundary Context (the Espoo Convention). This requires the Azerbaijan Government to provide initial notification to countries that may be subject to transboundary environmental impacts as a result of a development within Azerbaijan. An offshore oil development carries with it the small risk of a major oil spill. Such a scenario has been modelled for the ACG Phase 1 and Phase 2 developments and the results indicate that should such a spill occur, there is the potential for transboundary impacts. It is currently assumed that the Phase 3 development carries a similar risk. For this reason AIOC has forwarded to the Azerbaijan Ministry of Ecology and Natural Resources the ESIA scoping report for Phase 3, for onward delivery to the Caspian littoral states. The littoral states are required to respond to the Ministry indicating whether they wish to participate in the ESIA process. Should the Ministry receive confirmation from any of the littoral states that they wish to participate, this PCDP will be updated to reflect the planned consultation with those states. This document will

22 then also be circulated to the littoral states wishing to participate. 6.2 Schedule of Consultation Activities & Plan for Integration with ESIA & Project Activities It is not possible to provide a precise plan for consultation activities and their integration with the ESIA and project activities for two main reasons: The ACG Phase 3 development is still at the 'concept' stage with key decisions on project options still to be made (expected by August, 2003); and The ESIA has not yet been tendered so its timescale is not yet known precisely. Therefore, the schedule of consultations and linkages to the ESIA and project activities are presented with indicative timings. Once timings are known the PCDP will be amended accordingly to ensure it is current with ESIA/project activities. The indicative consultation schedule is shown in Table 2. Table 2: Consultation Plan and links to ESIA and Project Activities Consultation activities 1. Three workshops with stakeholders in Baku April Consultation meetings in Sangachal and Umid with community stakeholders (listed in section 6.1) May Interviews with representatives of Garadagh Executive Power and Manager of the Information Centres May 2003 Consultations and interviews with stakeholders as necessary Holding statements ESIA/Project Activities Scoping and preparation of Terms of Reference (ToR) for the ESIA (April - July 2003) The results of the scoping meetings will be summarized in a Scoping Report. The results will form the basis for the ToR. Also, issues raised may be used to assist decision-making by AIOC in the continuing design work for Phase 3. Implementation of ESIA and preparation of draft ESIA Report (August June 2004 During ESIA work there may be a need to obtain additional baseline data on socioeconomic and other characteristics. Also, there may be a need to refine impact prediction work to make it more focused and relevant. In such a situation 'follow on' consultations with stakeholders and/or consultations de novo with other stakeholders may be required to assist the ESIA. Also, if stakeholders request meetings to discuss the ESIA progress and preliminary results then meetings may be held at the discretion of AIOC. 18

23 1. Announcements in press and local notices in public places of details regarding the consultation process and period allowed for commenting. 2. Draft ESIA Report posted on the website. 3. Copies of Executive Summary available at key locations with good public access (in Azeri and Russian). 4. Copies of draft ESIA Report available at key locations with good public access (in Azeri and Russian). 5. Workshops held with Baku-based stakeholders (identical to those consulted during Scoping consultations). 6. A public meeting held in Baku. 7. Focus group consultation and open day 1. Final ESIA Report posted on the website. 2. Copies of final ESIA Report available at key locations with good public access (in Azeri and Russian). A programme of consultations is already in place from Phase 1. This will continue throughout Phase 3 and into the operational phase of the project. The Environmental Management System will be used to assess the performance against mitigation and control measures, and consultation will feed into measurement of performance. Draft ESIA Report (Environmental Statement) June - August 2004 (based on 60 day period for comments to be received by AIOC) Comments will be collated and analyzed using a standard reporting template. AIOC responses will be recorded in this template. The completed template with an account of consultations undertaken will be included as a section in the final ESIA Report. The comments received may lead to changes in the draft ESIA Report and, thus, determine to some extent the contents of the final ESIA report. Also, they may lead to changes in proposed project design and implementation actions. In line with the need for feedback to consultees, the summary of comments received and AIOC responses will be issued as soon as possible after completion of the 60-day consultation period. Final ESIA Report (Environmental Statement) August 2004 Post ESIA Report (Environmental Statement) Project Consultations Quarter et seq. Phase 3 construction actions will begin, followed by the operational phase. Regular, systematic and structured consultations between the terminal management and local stakeholders will play an important role in assisting implementation of effective impact management. Impact management is likely to involve amendments to operational practices and their timing. An evaluation report of PCDP effectiveness will be prepared and reported to a senior manager (see Section 6.5 below) and used to assist future ESIA consultation activities 6.3 Allocated Budget for the ACG Phase 3 ESIA Consultation The total allocated budget for the ACG Phase 3 ESIA Consultation process will be required to encompass five key components: media management activities to be undertaken and/or co-ordinated by the AIOC 19

24 Government and Public Relations (GPR) Department; issues management and stakeholder analysis activities to be undertaken through the collaboration of the AIOC GPR and HSE Departments; activities to be undertaken and /or co-ordinated by the individuals within the AIOC HSE Department responsible for management of the ACG Phase 3 ESIA process; community liaison activities to be undertaken and / or co-ordinated by the STEP team on behalf of the ACG Phase 3 ESIA project team; and activities to be undertaken and / or co-ordinated by the successful external consultant contracted to undertake the ESIA and prepare the associated Environmental Statement on behalf of AIOC. As a consequence of the later bullet point, the total allocated budget for the ESIA Consultation process will need to be determined following technical and commercial review of the Tender Documents received in response to the Invitation to Tender for the ACG Phase 3 ESIA. It is anticipated that, as far as practical, the execution of the consultation programme for ACG Phase 3 ESIA will be co-ordinated with existing and planned activities and initiatives for other phases of the ACG project. As such the allocated budget for the programme may be shared. 6.4 Management of Media Publicity Management of Media Publicity is the primary responsibility of the Government and Public Relations (GPR) department within AIOC. The GPR department has provided the following support to previous ESIA Consultation processes for the ACG project and it is anticipated that this same support will be available for the ACG Phase 3 project: Preparation of Holding Statements for key issues, in collaboration with the HSE department; Preparation of Question and Answer Sheets on key issues; Preparation of fact sheet handouts for use at public meetings; Preparation and dissemination of Press Releases; and Management of media enquiries. Requirements for support for management of media publicity for the ACG Phase 3 EISA consultation process will need to be discussed with the GPR department so that they can be integrated in the (HSE) External Communication Plan. 6.5 Management and Staff Resources Allocated to the Plan Tasks Within AIOC the responsible senior manager for the ACG Phase 3 Project is the Phase 3 Project Manager. His primary responsibility is to ensure that the ESIA decision on approval is delivered without impeding the project schedule. The Phase 3 Environmental Manager reports to the Phase 3 Project Manager and has overall responsibility for the entire ESIA process for Phase 3. This includes the adequacy of the ESIA process, the quality of the documentation and the effective implementation of the PCDP. In particular, she will ensure that the report of the evaluation of the Phase 3 PCDP is circulated to appropriate AIOC staff and that the lessons learnt are incorporated into future ESIA consultation activities. 20

25 She will be responsible for overseeing the implementation of the PCDP and will be supported by other HSE and GPR staff, as required, with respect to the day-to-day management of PCDP implementation. In particular, she will ensure that the activities outlined in Table 2 above are implemented effectively and on schedule. She will ensure, finally, that the effectiveness of the PCDP is evaluated. Figure 5 below presents a flow diagram showing the interfaces between the ACG Phase 3 ESIA Team and the other departments providing support to the public consultation and disclosure process. 21

26 Figure 5 AZERI, CHIRAG & GUNASHLI FULL FIELD DEVELOPMENT PHASE 3 Sangachal Terminal Expansion Project Community Liaison Environmental & Social Advisor Manager of Human Development Centre Manager of Information Centres World Vision Management Resources for ACG Phase 3 Public Consultation & Disclosure Process ACG Phase 3 Project Manager ACG Phase 3 ESIA Manager HSE Department (incl. Phase 1 & 2 HSE Managers) Government & Public Relations Deparment Management of Media Publicity and Stakeholder Analysis 22

27 7. EVALUATION CRITERIA FOR ASSESSING PCDP EFFECTIVENESS The PCDP will be evaluated against the goals set out in the Introduction. These goals are to ensure that; adequate and timely information is provided to project-affected stakeholders; these stakeholders are given sufficient opportunity to voice their opinions and concerns; and these concerns influence the ESIA process and project decisions. In addition, there are a number of activities to be implemented and outputs to be produced accompanied by time 'milestones'. The evaluation will be based on extent to which the activities and outputs have been undertaken according to the plan and within the specified time limits. In addition, the extent to which the goals have been achieved will be assessed, partly, depending on the extent to which the activities and outputs have taken place effectively. AIOC will undertake the evaluation. A brief Terms of Reference will be written to guide the evaluation. The evaluation will require interviews with AIOC staff and selected stakeholders and an examination of written records and materials pertinent to the implementation of the PCDP. The evaluation results will be presented in Table 3. This table will also provide a format for undertaking the evaluation. 23